Tax analysis: In Candy, the First-tier Tax Tribunal (FTT) decided that paragraph 34 of Sch 10 to the Finance Act 2003 (FA 2003) provides a remedy when no other relief is available and therefore permitted the taxpayer (C) to claim relief for SDLT paid on a contract that was substantially performed but not completed despite relief under another provision, FA 2003, s 44(9), being out of time since that provision required the relief to be claimed by amending the return.
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